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NDA Submission to the Department of Justice Equality and Law Reform
DRAFT NATIONAL PLAN FOR WOMEN
2001-2005
SUBMISSION TO
THE DEPARTMENT OF JUSTICE, EQUALITY
AND LAW REFORM
FEBRUARY 2002
TABLE OF CONTENTS
TOC o 1-1 1Summary of key recommendations PAGEREF _Toc1457517 h 2
2Introduction PAGEREF _Toc1457518 h 6
3Context PAGEREF _Toc1457519 h 7
4Draft 1 National Plan for Women Part 1: Government commitments PAGEREF _Toc1457520 h 10
5National Plan for Women Part 2: statistics and performance indicators PAGEREF _Toc1457521 h 12
6Income Adequacy PAGEREF _Toc1457522 h 13
7Health PAGEREF _Toc1457523 h 17
8Education PAGEREF _Toc1457524 h 22
9Conclusion PAGEREF _Toc1457525 h 26
Summary of key recommendationsThe NDA acknowledges the value and magnitude of the task of using the UN Platform for Action and the Beijing Declaration 1995 as a framework to integrate all Government commitments and womens aspirations into a single plan for women. The aim of the NDA in making this submission is to strengthen the National Plan for Women by ensuring that it addresses explicitly the needs and concerns of women with disabilities. Summary of overarching recommendationsIn pursuance of that aim the NDA makes the following recommendations.
Plan reworkedTo be truly reflective of Government policy and to meet the needs of women with disabilities, the Draft National Plan for Women be comprehensively reworked in order to integrate fully:
existing relevant Government policy in all policy areas
an approach to equality in keeping with recent Irish equality policy and practice and the equality objectives, including equality proofing of the Programme for Prosperity and Fairness
the government commitment in the Programme for Prosperity and Fairness to the accessibility of public services. This should include the dimensions of:
accessible physical premises
accessible information
accessible services
the insights already available into the specific needs of women with disabilities and of women carers of people with disabilities
Disability / Equality training
In all twelve Beijing platforms disability/equality training be provided for all relevant personnel in publicly funded services.
Actions and indicatorsIn all twelve Beijing platforms:
specific initiatives be taken to implement, monitor the implementation and evaluate the impact of the National Plan for Women
specific initiatives for women with disabilities be included in all these processes for implementing, monitoring and evaluating the Plan.
meaningful qualitative and quantitative indicators be developed specific to women with disabilities.
Capacity buildingWomen with disabilities be supported and resourced to capacity-build, to network and to develop their own specific political agendas so that their unique voices can be heard. This should be a key element in the national womens plan.
Disaggregation of dataThat in all sectors data gathered should be disaggregated on the nine grounds for discrimination including disability and gender.
Summary of key recommendations income adequacy
Access to an adequate income as a rightBy the end of the National Plan for Women
The basic income supports for women should be benchmarked at 27% of the average industrial wage
All women with disabilities should have a pension in their own right equal to the non contributory old age pension
Flexibility in the setting of pensionable age should be considered so as to enable older disabled women to continue to work if they choose to do so
Women in receipt of short-term disability related paymentsResearch should be undertaken during the early stages of the plan on the number of women on the various disability related payments, the length of time on such payments and reasons why there are more women on short term allowances than men.
Income support marital status
All income support measures should be reviewed in terms of their impact on single and married/cohabiting women. Income support should be paid to married or cohabiting women working in the home. (ref CSPD)
Women with disabilities in residential careThose women with disabilities in residential care who meet the eligibility criteria should receive income support as a right.
Costs of living with a disabilityA Costs of Disability Payment should be introduced as recommended in the Commissions Report to cover the extra costs associated with disability.
Women as carersBy the end of the National Womens Plan Health Boards should put in place support services for women carers, such as respite care, training, local community supports and networks.
Means test on Carers AllowanceThe means test on Carers Allowance be reviewed to ensure that families in receipt of the average industrial wage qualify for the Allowance.
Cost of providing careA Cost of Providing Care payment be introduced to cover the costs of heating, food and other expenses incurred as a result of providing full time care.
HealthReference to Government commitments
The National Plan for Women, Section 3 Women and Health, be expanded to include all key Government commitments in health and disability, notably Quality and Fairness.
Government commitments and the Beijing Platform for ActionGovernment commitments and policy in health be comprehensively evaluated against the Beijing Health Strategic Objectives and Actions and where necessary amended to reflect those undertakings.
Implementation of government commitments in healthIn implementing, monitoring implementation, and assessing the impact of Government health policy, including all parts of Quality and Fairness, specific initiatives for women with disabilities be included. The Plan for Womens Health 1997 1999The Plan for Womens Health 1997 1999 be updated in the light of Quality and Fairness and of other key Government disability policy documents. In updating the Plan, specific actions and progress indicators be developed for women with disabilities in the following key areas.
All health policy and plans to include specific initiatives to meet the health needs of women with disabilities
removing any attitudinal barriers to health care by disability/equality training
comprehensive assessment of need and support co-ordination across all services
training and employing sufficient numbers of health personnel in key care and therapy areas
providing health and personal social services of sufficient amount and quality to enable women with disabilities to live and participate effectively in their communities of choice
making all health premises and information accessible
Summary of Key Recommendations EducationIndicatorsThat meaningful qualitative and quantitative indicators are developed to record progress in participation of women with disabilities in education and training.
Policy StatementsAll educational/training institutions should develop and implement Equal Access and Participation Policy Statements with specific reference to women with disabilities.
Accessible environmentSpecific action plans be drawn up by the Department of Education and Science and education/training institutions detailing actions for creating an accessible environment for education/training.
CarersThe development of alternative targeted initiatives to address the education/training needs of carers.
IntroductionThis density of womens groups and associations in Ireland today has the potential to strengthen the voice of women for change. Despite this, the voices of some women, traveller women, asylum seekers, older women and women with disabilities are heard only faintly in the crowd.
(Pauline Conroy: Reflecting at the Crossroads, 2001:9)
We all need to consider how we can widen the circle and bring about the inclusion of women with disabilities into both the womens movement and the mainstream of everyday life. The experience of women with disabilities has been and continues to be one of exclusion
(Jacqui Browne: The Inclusion of Women with Disabilities in the National Plan for Women, 2001:1)
Mandate of the NDAThis submission is made under the mandate of the National Disability Authority Act, 1999. This Act establishes the National Disability Authority (NDA). Among the principal functions of the Authority are:
To act as a central, national body which will assist the Minister (for Justice, Equality and Law Reform) in the co-ordination and development of policy relating to persons with disabilities (National Disability Authority Act 1999 Sn)
In the NDA Act disability is defined as
in relation to a person, means a substantial restriction in the capacity of a person to participate in economic, social or cultural life on account of an enduring physical, sensory, learning, mental health or emotional impairment;
This broad definition is used in this submission unless specified otherwise.
The Report of the Commission on the Status of People with Disabilities In preparing this submission we have drawn on the consultation conducted by the Commission on the Status of People with Disabilities between 1993 and 1996. This consultation process was the most extensive ever conducted in relation to people with disabilities and their families. Much of the analysis and recommendations in the Strategy for Equality, the Report of the Commission (CSPD) remain valid today. Implementation of the Report is a priority of Government policy for people with disabilities. (Action Programme Fianna Fáil and the Progressive Democrats in Government).
The Commission recommended that various steps be taken to ensure that women with disabilities are enabled to participate at all levels of society (CSPD pp. 54 55 and pp227-228). NDA Response to Draft National Plan
The NDA welcomes the Draft 1 National Plan for Women (2001-2005) as an important initiative by the Department of Justice, Equality and Law Reform and congratulates the Department on its consultation process. We acknowledge both the value and the magnitude of the task of using the UN Beijing Platform for Action as a framework to integrate all Government commitments to women, and womens aspirations, into a single document.
However, we find that the Draft 1 Plan for Women does not meet the needs of women with disabilities. We recognise that the comments we make in this submission are directed as much to the Ministers and Government Departments whose policies are included in the Plan as they are to the DJELR in its task of compilation. Nevertheless we believe it is time for all analysis of issues relating to women to address issues wider than gender with regard to differences.
While the Plan makes some mention of women with disabilities (para 1.10, for example), it fails to integrate women with disabilities sufficiently into policy and objectives. In this submission we suggest ways in which the Plan could be improved and made more comprehensive. ContextIntersectionality and GenderFrom the late 1960s onwards, second wave feminism changed the political agenda in Ireland as elsewhere, by adding an awareness of, and attention to, the effects of gender as a form of structured inequality (Galligan, 1998; OConnor, 1998; Stetson and Mazur, 1995, for example). Subsequently, developments in feminist thought over the past three decades have added complexity to the picture by recognising the intersectionality between gender and other forms of social stratification and thus acknowledging that gender-based inequalities are not the only disadvantages facing many women. There has been increased understanding of the differences between women as well as of their commonalties based on gender. This has led to substantive analyses of the interconnections between gender inequalities and inequalities derived from other forms of social stratification, in the lives of women with disabilities and other disadvantaged women. (Good, 2000).
It is now increasingly recognised that, if the lives of the majority of women (as opposed to those of the privileged few), are to be improved, then policies need to be based on a full understanding of womens multiple identities and of the complex inequalities which they face. To be effective, a national plan for women can no longer be based on a simplistic and undifferentiated focus on women as a single category, with only token gestures towards inclusion of difference. Rather, the interrelationships between inequalities need to be addressed in a systematic and comprehensive way.
Recommendation
We recommend that the National Plan for Women be revised in keeping with current feminist analyses.
Irish Equality FrameworkThere is now a strong Irish equality framework into which a sophisticated and differentiated national plan for women can be fitted. This is outlined in several places. For instance, Framework 111 of the Programme for Prosperity and Fairness includes clear Equality Objectives and signals the commitment to equality proofing. (PPF 98). Equality proofing is a strategy aimed at ensuring that marginalised people and their requirements are included from the start in the development of structures, policies and practices.
The equality legislation of the late 1990s (e.g. the Equal Status Act) bans discrimination on nine grounds, those of age, marital status, family status, disability, sexual orientation, religion, race and membership of the Traveller community, as well as gender. These are not discrete categories, for in real life there are connections, overlaps and multiple identities. For example, a disabled, lesbian refugee would experience inequality on the basis of several aspects of her identity: not only gender, but also disability, sexual orientation and ethnicity. If her situation were to be improved by government action this could only be done through policy which was sensitive to all aspects of her situation.
To ensure the rights to equal treatment established by this legislation, and to accommodate diversity, the Equality Authority has produced a Support Pack.
Recommendation
We recommend that the national plan for women be revised in order to include an approach to equality which is more in keeping with recent Irish equality policies and practice and the equality objectives, including the strategy of equality proofing, of the Programme for Prosperity and Fairness.
In relation to women with disabilities this means, first, that attention needs to be paid to how disability and gender interact in the lives of women with disabilities. Second, it means that the Plan must recognise that women with disabilities sometimes also belong to other categories of disadvantage and inequality. This recognition must be systematically fed into the thinking across all the policy fields covered in the plan. This will require integrated thought and a sophisticated mainstreaming approach (see for example, Cornell, 1992, Lister, 1996, Rees 1998).
The current draft plan contains elements of such integrated thinking. For example, part 1, section 1 speaks of family friendly polices, anti poverty programmes and other cross cutting measures, and of the need to inform the plan with their thinking. This approach needs further development. This would require not alone acknowledging these measures in the listing of relevant government commitments contained in part 1, but also integrating this dimension into the statistics and indicators selected in part 2. These proposals are discussed further in section 5 of this submission.
Women and Disability Women with disabilities face inequalities and disadvantage based on gender, on disability and on complex interactions between these two forms of social stratification. They also find themselves marginalised both in the womens movement and in the disability movement (Browne, 2001; NRB, 1991, 1995, CSW 1994). Yet women with disabilities form a significant minority within Irish society, totalling an estimated minimum of 150,000 Irish citizens.
Recommendations
We recommend that:
women with disabilities be supported and resourced to capacity-build, to network and to develop their own specific political agendas so that their unique voices can be heard. This should be a key element in the national womens plan.
the insights already available into the specific needs of women with disabilities and of women carers of people with disabilities be properly integrated into every section of the draft plan.
Sources for this could include the following: the report of the Commission on the Status of People with Disabilities (1996), Murray and OCarroll (1998), NRB (1991, 1994, 1995). Submissions by groups of women with disabilities to this consultation process will also provide insights and ideas. To assist in the process of consulting with people with disabilities the NDA is completing Guidelines to Consultation which will be available from the NDA shortly.
Accessibility of Public Premises
In the Programme for Prosperity and Fairness the government stated its commitment to each government Department taking reasonable steps to make its services and those of agencies under its remit accessible to people with disabilities. (PPF p 100). Accessible includes the following dimensions:
accessible physical premises
accessible information
accessible services.
Recommendation
The National Plan for women should include the government commitment to the accessibility of public services where this is relevant in all twelve platforms. This should include the dimensions of:
accessible physical premises
accessible information
accessible support services
Draft 1 National Plan for Women Part 1: Government commitmentsThe NDA in this submission is focusing on the three policy areas chosen by the Authority for special attention during the first phase of its strategic plan 2000-2003:
income adequacy
health
education. (NDA, 2001).
They are intended to provide examples of what needs to be done for all 12 platforms if the national plan for women is to be truly national and to include women with disabilities fully within its remit.
General pointsComprehensive inclusion of all Government commitmentsWe find that the Draft as it stands does not adequately reflect existing Government commitments.
Recommendation
We recommend that the Plan should be comprehensively reworked to ensure that existing relevant Government policy in all policy areas is included.
Within stated Government policy and commitments the NDA sees substantive areas where improvements should be made for women with disabilities. This is consistent with the Aspirations dimension of the Plan. In the specific policy areas of this submission recommendations include:
known government policy commitments which are absent from the plan
policy statements which have yet to be implemented
areas where policy changes are needed.
Equality Objectives The PPF (p98) includes a commitment to the learning phase of equality proofing across the nine grounds. The initiatives to be undertaken include pilot projects in the public sector, research into the relationship between inequalities and poverty, equality proofing through the SMI in the civil service, North/South cooperation on the development of equality strategies, data collection, and equality reviews and action plans in the private sector. (Mullaly and Smith, 1999: 44-50). This learning phase is to run from 2000 2003. The NDA is of the view that it needs to be integrated into part 1 of the National Plan for women as a relevant government commitment. Section 5 8 show how this could be done in relation to poverty, education and health.
Beijing PlatformThere are 12 areas of concern listed under the Beijing Platform, all of which have specific implications for women with disabilities. Three of these will be examined in detail in the following sections. However, it is also important to note the relevance of the other nine areas. Much further work needs to be done but it can already be pointed out in relation to these that women with disabilities in Ireland are likely to:
have specific concerns about violence, both on the basis of disability and of gender (see Wilson, 2001)
have specific experiences in situations of war and armed conflict
have greater need than other women for support towards reducing their under representation in power and decision-making fora
have disability related as well as gender related human rights issues
have even greater problems than other women in relation to media representation of their lives and their needs
have a different experience of childhood than their able-bodied sisters
be excluded from equal participation in society, including paid work, by barriers which are physical and environmental, structural and institutional, and attitudinal.
Part 1 of the National Plan for Women should outline the ways in which government commitments to equality proofing and to the rights of women with disabilities will address some of these issues. Such measures would make progress to reduce the disadvantages and hardships experienced by women with disabilities and their families.
National Plan for Women Part 2: statistics and performance indicatorsGeneral pointsThe learning phase of equality proofing contains a dimension relating to databases and statistics which should be integrated into the Plan. This can then be added to the statistics section in part 2(a) of the Plan and also used to expand the performance indicators proposed in part 2 (b) to include some which are disability sensitive. We have seen that data collection is one of the main categories of action during the learning phase of equality proofing. It consists of taking initiatives to address the data deficits that exist in relation to the new grounds covered under the equality legislation (Mullaly and Smith, 1999:9)
Mullally and Smith argue that:
The cornerstone of an effective equality proofing process is an adequate database. The lack of disaggregated (sic) data in many areas of economic and social policy has created difficulties in monitoring and evaluating equality strategies adopted to date
(1999:48)
They point out that creating disaggregated data is complex and may need to be tackled in a variety of ways. Initiatives will include
extension of official statistics to include questions on the nine grounds
expansion of existing systems of data collection by service providers to include data on the nine groups
inclusion in Information Society Project initiatives of a focus on data collection across the nine grounds.
creating a single statistical product containing data on the nine target groups which would be regularly updated and publicly available
This work needs to be fed into the statistical section of the Plan and to the performance indicators to be used to assess the National Plan for Women, in such a way that there are relevant indicators to measure the Plans impact on women with disabilities.
The recommendations in the next three sections suggest areas where statistics should be collected and performance indicators for detailed analysis in poverty, health and education. Similar work needs to be done for the remaining nine areas of concern under the Beijing programme.
Income AdequacyIntroduction
Two broad issues are central to the elimination of the ongoing cycle of women with disabilities and poverty. The first issue concerns womens right to access an adequate income. The second, which cuts across and interacts with the first, is the role of Irish women as carers. In all of these situations women with disabilities and carers of persons with disabilities feel very isolated and unsupported. This ongoing sense of isolation may lead to secondary mental health problems.
There is a clear link between women with disabilities and poverty. Households headed by a person with a disability have one of the highest risks of poverty, using the measure of consistent poverty adopted by the National Anti- Poverty Strategy. The figures from the 1998 Living in Ireland Survey show that the risk of poverty for households headed by someone who is ill or disabled is 28%. This is one of the highest risks of poverty (households headed by someone who is unemployed have the highest risk at 30%) compared to a risk for all households of 8%.
The key issues include:
inadequate income levels
duration on short-term disability payments
married/cohabiting womens entitlement to disability allowance
access to disability allowance for women with disabilities in residential care
costs of living with a disability
Issue: Access to an adequate income as a rightThere are three interrelated issues, which need consideration.
Married/cohabiting women who become disabled while working in the home are excluded from income maintenance supports and have to depend on their spouses/partners income
Access by married/cohabiting women who become disabled to labour force re-entry back to work employment schemes is restricted by the criteria set down. This results in their ongoing participation in various employment-related schemes e.g. community employment schemes, back to work allowance scheme, back to education allowances. This process continues their economic isolation and exclusion. In addition there are disincentives that hinder taking up employment, such as the loss of the medical card and the benefits of the free schemes
Older women with disabilities are a particularly vulnerable group. The Household Survey shows that elderly or retired women with a disability who head a household are more likely to end up in poverty. This scenario was reinforced by the findings of the 1994 Report on Monitoring Poverty Trends which found that women in Ireland experience greater risk of poverty than men, largely due to the risk of poverty for single adult households (mainly headed by women) and households headed by someone working fulltime in the home( again mainly women)
Recommendation
By the end of the National Womens Plan
The basic income supports for women should be benchmarked at 27% of the average industrial wage.
All women should have a pension in their own right equal to the non contributory old age pension
Flexibility in the setting of pensionable age should be considered so as to enable older disabled women to continue to work if they choose to do so.
Issue: Women in Receipt of short-term disability related paymentsWomen in receipt of disability related payments remain on short- term payments for longer periods than men on the same disability related payments. The period of time involved for some women to remain in receipt of short-term payments is several years.
Invalidity Pension (DSCFA December 2001)
Male 27849, Female 22576, Total 50425
Disability Benefit (not exact figures)
Male 20400 Female 30600 Total 51000
Recommendation
Research should be undertaken on the number of women on the various disability related payments, the length of time on such payments and reasons why there are more women on short term allowances than men.
Issue: Women in Receipt of Disability Allowance:Women in receipt of Disability Allowance who marry a partner in employment lose their entitlement to the disability allowance through the means test. Women who marry or cohabit with someone on Invalidity Pension and Disablement Pension will also lose their entitlement to Disability Allowance.
Recommendation
All income support measures for people with disabilities should be reviewed in terms of their impact on single and married/cohabiting women. Income support should be paid to married or cohabiting women working in the home. ( ref Equal Status)
Issue: Women with Disabilities in Residential CareThere are a number of women with disabilities living in residential centres who do not receive any income payments from the state. Since 1996 when the DSCFA took over responsibility for the DPMA, now called the Disability Allowance, those entering residential care retain their Disability Allowance. This has resulted in an unfair and unequal situation.
Recommendation
Those women with disabilities in residential care who meet the eligibility criteria should receive income payments as a right.
Issue: Costs of Living with a DisabilityThere a number of Health Board and Social Welfare Payments that could be classified as costs of disability related payments but they are means tested and limited by strict criteria. The Commission on the Status of People with Disabilities recommended that a Cost of Disability Payment be introduced to cover the additional costs associated with having a disability.
Recommendation
A Cost of Disability Payment should be introduced as recommended in the Commissions Report to cover the extra costs associated with:
equipment
mobility and Communication (travel and telephone)
living Costs (fuel, food, clothing etc)
medical care and assistance (including personal assistants)
Women as Carers
Women continue to bear the primary responsibility for caring in Irish society. There is a direct relationship between women as carers and womens poverty. The absence of supports and adequate financial payments for caring continues the cycle of women being caught in a role that Irish society does not value and reward.
Caring is predominantly a womens issue and women have history of taking on the role of carer which results in their ongoing exclusion from economic activity. The Carers Association of Ireland estimates that there are approximately 100,000 carers in Ireland, 80% of whom are women. The Statistics on Carers Allowance and Carers Benefit (see below) confirm that women are the main carers in Irish society, with 80% of those receiving Carers Allowance being women. Those statistics also confirm that of the estimated 80,000 women cares fewer than 13,500 receive any financial support for their caring role from the state.
Carers Allowance:
Male3473Female13,005Total16478
Carers Benefit
Male 57 Female 381 Total 438
Source: DSCFA Annual Report 2001
Key issues
The key issues for women carers are:
lack of support services
means test of the carers allowance
cost of providing care
Lack of support services
The Commissions Report identified several areas where support services are lacking or inadequate. These include respite care, training, local community supports and networks. Many of these issues are identified for Acti
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